Primary Stakeholders, Functionaries Are Women: Telangana High Court Upholds Female Reservation For Anganwadi Supervisor Post

The Telangana High Court has upheld the State Government's order reserving posts of Extension Officers Grade-I and Grade-II (Anganwadi Supervisors) exclusively for women, holding that the policy is a valid exercise of the State's power under Article 15(3) of the Constitution. [2026 LiveLaw (Tel) 101]

The Court observed that the beneficiaries of the Integrated Child Development Services (ICDS) scheme are predominantly women and children and that the Government's policy decision could not be interfered with merely because men were also capable of performing the duties attached to the posts.

Article 15(3) of the Constitution allows the State to make special provisions for women and children, focussing on substantive equality and ensuring that such provisions do not amount to discrimination which would be unconstitutional.

Dismissing two writ petitions challenging the policy, Justice T. Madhavi Devi observed:

"Though the job chart which has been reproduced by the petitioners in the writ affidavit does not demonstrate that such functions can be discharged only by women candidates, this Court finds that the stake holders or the beneficiaries of the scheme are children, adolescent and young girls, pregnant women and lactating mothers and the primary functions under the scheme are being performed by Anganwadi workers in Anganwadi Centres and therefore, all the stake holders as well as the primary functionaries are women and it is in these circumstances that the Government has come to the conclusion that the posts have to be exclusively reserved for women."

Relying on the Supreme Court's decision in Vijay Lakshmi v. Punjab University, the Court held that the Government was empowered to make such special provisions for women under Article 15(3) of the Constitution and that such policy decisions, taken as a "preventive or precautionary measure", ordinarily do not warrant judicial interference.

The petitions challenged an amendment introduced through G.O.Ms. No.14 dated June 27, 2013, whereby only women candidates were made eligible for appointment as Extension Officers Grade-I and Grade-II (Supervisors) in the Women Development and Child Welfare Department by any method of recruitment. Consequentially, the petitioners also challenged recruitment notifications issued by the Telangana State Public Service Commission (TSPSC) in 2022 for 181 posts of Extension Officer (Supervisor) Grade-I and 23 posts of Women and Child Welfare Officers and Child Development Project Officers, which restricted eligibility to women candidates.

The petitioners, who were male candidates, contended that the amendment violated Articles 14, 19(1)(g) and 21 of the Constitution by completely excluding men from consideration. They argued that the duties of Extension Officers, such as supervising Anganwadi Centres, monitoring nutrition programmes, maintaining records, coordinating with health authorities and assisting Child Development Project Officers, could be effectively discharged irrespective of gender. They further relied on Rule 22-A of the Telangana State and Subordinate Service Rules, 1996, particularly the proviso to Rule 22-A(1), which states that "such absolute preference to women shall not result in total exclusion of men in any category of posts."

The State defended the policy, submitting that Extension Officers function as field-level supervisors overseeing Anganwadi Centres providing supplementary nutrition, pre-school education, health services and welfare measures to children, adolescent girls, pregnant women and lactating mothers. It was contended that the service delivery framework had been consciously designed keeping in view "the sensitivity and sensibilities of targeted beneficiaries" and to ensure a safe working environment for Anganwadi workers, who are themselves women. TSPSC submitted that it had merely implemented the Government's policy while conducting the recruitment.

Rejecting the challenge, the Court held that although the original 2000 Government Order prescribing guidelines for appointment of Extension Officers did not restrict the posts to women, the 2013 amendment represented a conscious policy decision of the Government.

The Court observed that while Rule 22-A(1) permits preference to women in posts for which they are "better suited than men", the proviso against total exclusion of men "cannot restrict the prescription of the rule itself." According to the Court, sub-rule (1) empowers the Government to assess the categories of posts for which women are better suited and frame an appropriate recruitment policy.

The Court acknowledged that the job chart by itself did not establish that the functions "can be discharged only by women candidates." However, it held that the nature of the beneficiaries and the functioning of the ICDS scheme justified the Government's decision to reserve the posts exclusively for women.

Distinguishing the decisions relied upon by the petitioners, including S. Renuka v. State of Andhra Pradesh and Dr. Alok Kumar Singh v. State of Uttar Pradesh, the Court observed that those cases involved reservations for judicial officers and medical specialists, where both men and women were equally suited to the posts. The Court held that those precedents were factually distinguishable and that the Supreme Court's decision in Vijay Lakshmi governed the present case.

Accordingly, the Court dismissed both the writ petitions and upheld the validity of the Government Order reserving the posts of Anganwadi Supervisors exclusively for women.

Case Title: Boorla Mahesh & Ors. v. State of Telangana & Ors.; 

Case Nos.: W.P. No. 37458 of 2022 and W.P. No. 37535 of 2022

Appearance: Ms. Rachana Reddy for the petitioners; Standing Counsel for TSPSC; Government Pleader for Services-II for the State.

Click Here To Read/Download Order

Citation: 2026 LiveLaw (Tel) 101